& in body of node shows nothing

I have something like this in my template.php

function theme_views_view_list($view, $nodes, $type) {
$fields = _views_get_fields();
if ($view->name == 'headlines')
....
$body = views_theme_field('views_handle_field', $field['queryname'], $fields, $view->field[1], $node, $view);

It works great but one day, one of my nodes had an "&" character in the body content which came from FCKeditor. This caused the resulting view to return an empty value for $body. However on that particular node, the body content displays. I removed the 4 character string "&" from the node body content, the $body value now returns a string for the node. Any ideas as to the cause?